ITAT Overturns CIT(A), Rules Excess Jewellery Stock as Business Asset, Not Undisclosed Income; Rejects Section 115BBE Application.

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....The assessee was found with excess stock of jewellery during a search operation. The Assessing Officer (AO) invoked provisions of Sections 69A and 69B, treating the excess stock as undisclosed income. The assessee explained that the difference between physical and recorded stock was due to goods received on approval but not entered in books, or bills pending from suppliers. The CIT(A) upheld the AO's action. The ITAT observed that as per CBDT circular, preference should be given to corroborative evidence over oral statements during searches. The assessee substantiated the transactions with evidence like supplier confirmations and GST returns, which the revenue could not dislodge. The retraction by the assessee was supported by evidence and .........